Lessons from Auschwitz Online Privacy Policy

Effective: 01/02/2021

1. Introduction 

The Holocaust Educational Trust (HET) created the Lessons from Auschwitz (LFA) Online Project to increase knowledge and understanding of the Holocaust for young people and to clearly highlight what can happen if prejudice and racism become acceptable. We have developed this privacy policy to inform you of the data we collect, what we do with your information, what we do to keep it secure, as well as the rights and choices you have over your personal information, in accordance with the Data Protection Act 2018 and any replacement legislation coming into effect from time to time.

Lessons from Auschwitz Online is a digital learning experience consisting of three live sessions and independent learning, all accessible through a bespoke online platform. Additionally, participants are encouraged to design and carry out a next steps project to share what they have learnt.

We collect personal data from teachers and students in order to coordinate participation. This information may be used by HET to inform individuals of other opportunities available from the Trust.

HET is the controller for the personal information we process, unless otherwise stated.

We are registered with the Information Commissioner’s Office (the ICO) with registration number Z5371798.

You can contact us either by phone, email or post.

Our Data Protection Officer is:

The DPO Centre Ltd. 

50 Liverpool Street

London

EC2M 7PY

Phone: 0203 797 1289

Website: www.dpocentre.com

2.  The information we collect

We only collect personal information that we know we will genuinely use and in accordance with the Data Protection Act 2018. The type of personal information that we will collect from participants, and which participants voluntarily provide to us on this project may include some or all of the following: 

  • Name
  • Contact information, including email address, postal address, and phone number
  • Emergency contacts’ information
  • Details of the school participants are from
  • Health data
  • Gender*
  • Religious data*
  • Ethnicity data*

*Gender, Religious and Ethnicity data are voluntary for participants to provide if they chose to do so. LFA collects these data for demographic statistical purposes only.

The legal basis for processing your data is based on:

  • Consent from participants – For participants to be part of the LFA Online Project and to enable them to receive marketing news if they have opted in
  • Vital Interests – Health, safety and welfare needs and concerns for those who partake on LFA Online Projects
  • Our legitimate interests – To help enable participants who have completed a LFA Online Project to become a HET Ambassador (more information on this can be found on the Ambassador privacy policy on the main HET website; www.het.org.uk)

3.  How we use participants’ information

  • To help with coordination of the project with participating schools, students, teachers, parents and guardians
  • To help with engagement for future HET programmes (including our Ambassador programme)
  • To comply with health & safety and child safety regulations
  • To maintain our databases which hold participants’ personal data
  • To conduct LFA live sessions (where sessions are recorded for safety and monitoring purposes, only HET presenters or their screens will be visible)

4.  Who we might share participants’ information with

We may share participants’ personal data with other organisations in the following circumstances:

  • Course outcome reporting and financing with the Department for Education (DfE) in England
  • Mail Chimp who help facilitate our emails and marketing e-newsletters if participants have opted in
  • Alban House who help distribute our hardcopy educational materials if participants have opted in

5.  Participants’ rights over their information

5.1.1   The right to be informed about our collection and use of personal data;

Participants have the right to be informed about the collection and use of their personal data. We ensure we do this with our internal data protection policies and through our external website policy. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

5.1.2   Right to Access Participants’ Personal Information

Participants have the right to access the personal information that we hold about them in any circumstances, by making a request. This is sometimes termed ‘Data Subject Access Request’. If we agree that we are obliged to provide personal information to participants (or someone else on their behalf), we will provide it to the participant or them free of charge and aim to do so within 30 days from when the participant’s identity has been confirmed.

We would ask for proof of identity and sufficient information about the participant’s interactions with us so that we can locate their personal information.

If participants would like to exercise this right, then they should contact us as set out below.

5.1.3   Right to Correction of Participants’ Personal Information

If any of the personal information we hold about a participants is inaccurate, incomplete or out of date, the participant may ask us to correct it.

If a participant would like to exercise this right, please contact us as set out below.

5.1.4    Right to Stop or Limit Our Processing of  Participants’ Data

Participants have the right to object to us processing their personal information for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If a participant would like to exercise this right, they should contact us as set out below.

5.1.5   Right to Erasure

Participants have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.

If a participant would like to exercise this right, they should contact us as set out below.

5.1.6    For more information about participants’ privacy rights

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. Participants can access them here https://ico.org.uk/for-the-public.

A participant can make a complaint to the ICO at any time about the way we use their information. However, we hope that a participant would consider raising any issue or complaint they may have with us first. The satisfaction of our participants is extremely important to us, and we will always do our very best to solve any problems they may have.

6. How long we keep information for

We retain a record of participants’ personal information in order to provide them with a high quality and consistent service. We will always retain a participant’s personal information for no longer than three years after which it will be automatically anonymized from our systems, so a individual can no longer be recognised. If an individual revokes their consent for being on the online project and requests removal of the data we will be sure to action this following their request as well.

7. Security

Data security is of great importance to HET and to protect participant data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure participants’ collected data.  We store participants’ data on our secure servers based in the UK.

We take security measures to protect participants’ information including:
 

  • Limiting access to our buildings to those that we have determined are entitled to be there;
  • Implementing access controls to our information technology;
  • We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard participants’ information across all our computer systems, databases, networks, websites.
  • We have entered into the standard global data processing agreement with Zoom to ensure protection of private information

8. Cyber Essentials

As well as the above security measures HET has also achieved Cyber Essentials certification which is reviewed annually. Copies of our certification is available if requested by contacting us below.

9. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). We recommend that participants check this policy regularly to keep up-to-date.

10.  Cookies

Please refer to our separate Cookie policy for how we use Cookies on our website and to change your consent.

11.  How to contact us

If a participant would like to exercise one of their rights as set out above, or if they have a question or a complaint about this policy, the way their personal information is processed, they should contact us by one of the following means:

By email: info@lfaproject.org.uk

By telephone: +44 (0)20 7222 4761
By post: BCM Box 7892, London, WC1N 3XX

 

 

Lessons from Auschwitz Online Terms and Conditions 

The following terms and conditions govern all use of the Lessons from Auschwitz Online platform, including any use or viewing of any content, services, and products available at or through the platform, by platform visitors and participants, both unregistered and registered. By accessing the LFA Online platform, you agree to all points below.

Your use of this site constitutes acceptance of these Terms and Conditions as at the first date of your use of the site. The Holocaust Educational Trust reserves the rights to change these Terms and Conditions at any time by posting changes online. Your continued use of this site after changes are posted constitutes your acceptance of this agreement as modified.

You agree to use this site only for lawful purposes, and in a manner which does not infringe the rights, or restrict, or inhibit the use and enjoyment of the site by any third party.

This site and the information, names, images, pictures, logos regarding or relating to the Holocaust Educational Trust are provided "as is" without any representation or endorsement made and without warranty of any kind whether express or implied. In no event will the Holocaust Educational Trust be liable for any damages including, without limitation, indirect or consequential damages, or any damages whatsoever arising from the use or in connection with such use or loss of use of the site, whether in contract or in negligence.

The Holocaust Educational Trust tries to ensure that the website is up-to-date and functioning well. However, it does not warrant that the functions and the material contained in this site will be uninterrupted or error free, that defects will be corrected, or that this site or the server that makes it available are free of viruses or bugs or represents the full functionality, accuracy and reliability of the materials.

Any communication or material that you transmit to, or post on, any public area of the site including any data, questions, comments, suggestions, or the like, is, and will be treated as, nonconfidential and nonproprietary information.

Commercial use or publication of all or any item displayed is strictly prohibited without prior authorisation from the Holocaust Educational Trust. Nothing contained herein shall be construed as conferring any licence by the Holocaust Educational Trust to use any item displayed. Documents may be copied for educational or personal use only on the condition that copyright and source indications are also copied, no modifications are made and the document is copied entirely. However, some documents and photos have been published on this site with the permission of the relevant copyright owners (who are not the Holocaust Educational Trust). All rights are reserved on these documents and permission to copy them must be requested from the copyright owners (the sources are indicated within these documents/photographs).

The Holocaust Educational Trust takes no responsibility for the content, privacy practices, accuracy or reliability of any website accessed by a link from our website. Other websites that we link to are owned and operated by third parties and we have no control over them. The fact that we include links to other websites does not mean that the Holocaust Educational Trust approves of or endorses any other third party website or the content of that website. We accept no liability for any statements, information, products or services that are published on or are accessible through any websites owned or operated by third parties.

These Terms and Conditions shall be governed and construed in accordance with the laws of England and Wales. Any disputes shall be subject to the exclusive jurisdiction of the Courts of England and Wales.

If these Terms and Conditions are not accepted in full, the use of this site must be terminated immediately.

Data Protection

The Lessons from Auschwitz Project and LFA Online are operated with the generous funding of the Department for Education in England.  Monitoring and equalities data may be shared with our funders in compliance with the GDPR and Data Protection Policies. Please review our LFA Online Privacy Policy above for more details on how we collect and use your data

Behaviour and Online Etiquette

If in the opinion of HET staff or other figures of authority – participants are behaving in a manner which may endanger or distress others, disrespect/cause offence to others, their participation in the project may be ended at any time.

We reserve the right to disqualify any participant from the project at any time.

Lessons from Auschwitz Online takes place in an online environment. Harassment, bullying, or rudeness to speakers, staff, guests, or other participants will not be tolerated. Any participant taking part in such behaviour will be removed from the course.

Online seminars will take place on the Zoom platform. We expect all participants to:

●          use their real names

●          remain on ‘mute’ when not actively contributing to a discussion

●          be dressed in appropriate clothing

●          be sat in a quiet environment, appropriate for listening, thinking and discussing challenging topics

●          be inclusive, respectful and polite at all times

●          allow all participants the time and space to share their thoughts

●          not take any photos, videos or screen-captures of the session

 

Safety and use of the online platform

●          The Virtual Reality (VR) part of Lessons from Auschwitz Online requires the safe use of your personal or school or college’s electronic devices. HET assume no responsibility for injury or damage to you or your property while engaging with this or any other content on the course.

●          Content on the platform may only be accessed and used by registered users of Lessons from Auschwitz Online.

●          Registration is linked to an individual user and login credentials must not be shared or redistributed for any purpose.

●          By uploading written content to the Lessons from Auschwitz Online platform, users agree that the Holocaust Educational Trust may display and re-use this content in marketing or other materials without compensation or notification.

●          Online sessions may be recorded for safety and monitoring purposes. Only HET presenters or their screens will be recorded.

The Lessons from Auschwitz Online platform is supported by the Department for Education in England. The platform and its content may not be used, altered or re-distributed without express permission from all stakeholders.